In March 2025, four Indonesian fishers filed a lawsuit in California against Bumble Bee Foods, a major U.S. tuna company. The fishers claimed Bumble Bee had violated the prohibition on forced labor under the Trafficking Victims Protection Reauthorization Act (TVPRA).
On November 12, 2025, a district court allowed the case against Bumble Bee Foods to continue beyond the motion to dismiss stage. This is an important decision, making it more likely that the four plaintiff fishers – who faced severe deprivation and abuse while out at sea – will eventually receive a remedy.
As the first human trafficking case brought against a U.S. seafood company for forced labor at sea, the judge’s order is a landmark victory for human rights and corporate accountability – and, especially, for the four fishers. While the plaintiffs still face a long path to justice, this result is a significant step towards that goal.
This blog post provides an update on the Trafficking Victims Protection Act (TVPRA) case against Bumble Bee tuna. It provides an overview of who the plaintiffs are, the history of the case, and the order denying Bumble Bee’s motion to dismiss, along with its implications for future accountability.
The Fishers
The four plaintiffs are Indonesian fishers who endured forced labor and numerous abuses on tuna fishing vessels. The manning agencies – recruitment companies that find placements for fishers – promised these workers decent wages and working conditions. However, the agents pressured the plaintiffs to sign contracts from the vessel owners and operators that instead trapped them in debt bondage.
Forced to pay recruitment fees and subject to extensive fines if they quit, the fishing companies coerced these men into remaining on the ships indefinitely. All four men struggled financially before being hired as fishers. One supported his wife and two children on the little income he could obtain from construction, farming, and other odd jobs, while another borrowed money from his mother, who was in the hospital, to pay the recruitment fees. Because the men could not pay off their employer-imposed debts, they had to keep working. Stuck in debt bondage, one plaintiff alleged that he was forced to pay nearly half of his $320 monthly salary and another had two-thirds deducted to pay various costs. In the end, at least two plaintiffs made no money from their time fishing, and one captain told a plaintiff he still owed $30 when he was finally freed.
The fishers also faced violence and neglect. Their captains beat them, provided insufficient food, and forced them to work through serious injuries without providing medical attention. Three plaintiffs resorted to eating bait fish to avoid starving, one lost part of his finger and suffered a lasting leg injury, and one had to treat severe burns with only Vaseline. The captains denied requests to leave, and the ships often stayed at sea for months at a time, trapping the workers.
The abuse these fishers experienced is emblematic of a widespread problem. Abuse aboard fishing vessels is well-documented, but it is difficult to hold those responsible – including companies – accountable for human rights abuses when they occur at sea. Often, the manning agencies and associated fishing companies recruit vulnerable populations such as migrants and individuals from impoverished backgrounds using deceptive tactics. Once at sea, the isolated nature of the work makes it easy for vessel owners and operators to avoid scrutiny for violent and neglectful behavior. Within this culture of impunity, fishing operations have a long history of human rights abuses.
The Case
In March 2025, the four plaintiffs in this case sued Bumble Bee for sourcing albacore tuna from fishing vessels that rely on forced labor. Bumble Bee is a U.S. company that sold this forced labor-produced tuna to grocery stores in the United States.
The fishers brought the case under two legal causes of action. First, they claimed Bumble Bee violated the TVPRA by using forced labor. In their complaint, the plaintiffs alleged that Bumble Bee “participated in a venture” with the fishing vessel owners and operators and benefitted from forced labor that they knew or should have known was occurring. Second, the plaintiffs claimed that Bumble Bee was negligent under California law. The fishers requested both injunctive relief – to prevent Bumble Bee from continuing to profit from forced labor – and monetary damages.
On June 2, 2025, Bumble Bee filed a motion to dismiss the lawsuit. On November 12, 2025, the court partially dismissed and partially granted the motion. Overall, this was a momentous decision that allowed the case to move forward to the discovery stage and closer to justice for the plaintiffs.
Most importantly, the court allowed the TVPRA claim to proceed, finding that the statute has extraterritorial application – meaning it reaches activities that took place outside the United States – in situations like these. Congress always intended for the TVPRA to apply extraterritorially , and this decision affirms that understanding of the law. As the court said, as long as the defendant is a U.S. citizen, a lawful permanent resident, or is present in the United States, and the plaintiffs meet requirements of a forced labor claim, the TVPRA covers activities anywhere.
In this case, the court found that the plaintiffs had met the pleading requirements for a TVPRA claim. The plaintiffs alleged the vessel captains used physical abuse and threats to force them to work and that Bumble Bee benefited from that forced labor by profiting off the sale of tuna obtained from the vessels. While Bumble Bee did not itself force the plaintiffs to work, the court found that it could still be held liable for profiting from participation in a venture with the fishing vessels that did. The plaintiffs alleged that Bumble Bee was in a venture due to its collaboration with the owners and operators of the fishing vessels to obtain environmental certifications and implement fishery improvement projects. The court agreed that this was sufficient to state a claim under the TVPRA.
Additionally, the court held that the complaint plausibly alleged that Bumble Bee knew or should have known about the forced labor scheme. It pointed to multiple public reports detailing the abuses on vessels supplying Bumble Bee with tuna. Moreover, Bumble Bee claimed to work directly with fleets and vessels and review their operations as part of a “Social Responsibility Program” – meaning the company should have detected labor abuses in its supply chain, including forced labor.
The court also allowed the plaintiffs’ negligence claims under state law to proceed. It found that the complaint sufficiently alleged that Bumble Bee had a duty to protect the fishers based on the “special relationship” between them. Generally, people only have a duty to prevent harm that results from their own actions. Thus, for Bumble Bee to have a legal duty to prevent harm caused by a third party, such as the fishing vessel operators, it must have had a relationship where it could and should have protected the injured fishers. Here, the complaint alleged that Bumble Bee established that relationship by setting policies and procedures related to vessel working conditions, reviewing vessel operations, and financing environmental certification projects as part of its Social Responsibility Program.
California courts also consider public policy factors to determine whether they should establish a special duty of care. In this case, the court weighed multiple factors in favor of establishing a duty for Bumble Bee to protect the workers from harm including moral blame, the societal goal of protecting fishers from forced labor, and the fact that it would not be “unduly burdensome or costly” for Bumble Bee to reach the human rights standards it allegedly set for itself. Public policy considerations thus bolstered the strength of the complaint’s special relationship allegations, helping the claim avoid dismissal.
The plaintiffs argued in the alternative that Bumble Bee owed them a duty of care under a theory of misfeasance, meaning Bumble Bee created a foreseeable risk of harm with its own actions. The court agreed that the alleged facts support this claim, as the complaint alleged that Bumble Bee controlled the vessels where the forced labor occurred and created opportunity and incentive for vessel captains to abuse their workers.
While overall this was a strong decision for the plaintiffs, the court did grant Bumble Bee’s motion to dismiss the claim for injunctive relief, finding that the TVPRA does not authorize injunctions as a remedy and that under California law, the plaintiffs had to allege a likelihood of future harm or irreparable injury, which they had failed to do. However, the judge granted leave to amend the complaint, allowing the plaintiffs an opportunity to plead such allegations and potentially revive their request for injunctive relief.
The Wider Implications
Following this order, the fishers still face a long road to justice. However, in allowing the case to proceed, the court has made a strong statement on the availability of legal redress for human rights abuses – including those that occur out of sight and far away at sea. After previous setbacks in this area, this ruling opens the door for accountability against U.S. companies for human rights abuses in their global supply chains.
The speed with which this case has proceeded is also cause for celebration. Just eight months after the plaintiffs filed the case, they are now able to proceed to discovery. In the past, too many TVPRA supply chain cases have been lost at the motion to dismiss stage. In Doe v. Apple, the D.C. Circuit dismissed a case against technology companies sourcing cobalt from mines using child labor and forced labor, finding that the descriptions of an arms-length buyer-seller relationship in the supply chain did not constitute participation in a venture with the mines. In Ratha v. Phatthana Seafood, the 9th Circuit dismissed claims against non-U.S. companies for insufficient contacts with the United States. It also dismissed the claims against the U.S. company Rubicon Resources LLC because Rubicon tried, but did not succeed in, benefiting from the forced labor venture – due to the fact that a U.S. company refused to accept Rubicon’s product, knowing it had been produced with forced labor. While Ratha is being reheard following a clarification from Congress, the plaintiffs in that case have now been waiting almost a decade for justice.
After these setbacks, advancing beyond the motion to dismiss stage in Akhmed is a significant victory for accountability under the TVPRA. As these cases often take many years to reach a verdict, the speed of the court’s order in Akhmed – released a mere five months after defendants filed the motion to dismiss – enables the case to move more quickly to a resolution that may finally compensate the fishers for the harm they suffered.
This case sends a message to U.S. companies, showing that they can be held accountable for human rights violations like forced labor in their supply chains. By standing up for their rights, these four plaintiffs are challenging seafood companies’ impunity for profiting from exploitation on fishing vessels. We hope this is the first step towards ending that impunity.
Dana Meskin was a legal intern at CAL in fall 2025.
